NALSAR Student Detained For Attendance Shortage Can't Take Supplementary Exams; Sympathy Can't Override Academic Rules: Telangana High Court
The Telangana High Court has refused to direct NALSAR University of Law to permit an MBA student to appear in supplementary examinations after she was detained for shortage of attendance due to prolonged illness. Holding that sympathy and equitable considerations cannot override mandatory academic regulations, the Court ruled that a student barred from writing end-term examinations for lack...
The Telangana High Court has refused to direct NALSAR University of Law to permit an MBA student to appear in supplementary examinations after she was detained for shortage of attendance due to prolonged illness.
Holding that sympathy and equitable considerations cannot override mandatory academic regulations, the Court ruled that a student barred from writing end-term examinations for lack of attendance is also ineligible to appear for supplementary examinations under the University's rules.
Justice Juvvadi Sridevi observed:
"Rule 5.3.5 stipulates that a student, who is not permitted to take End-Term Examinations on account of shortage of attendance, shall not be eligible to appear for the repeat examination and shall be required to re-register for the course. The Rule is couched in mandatory terms and leaves no discretion either to the respondent-University or to this Court to permit a student detained on account of shortage of attendance to appear in the supplementary examinations."
Emphasising the limited scope of judicial review in academic matters, the Court further held:
"Sympathy or equitable considerations cannot override the mandatory academic Rules, which are uniformly applicable to all the students. It is well settled that in matters relating to academic standards, eligibility and examination regulations, the scope of judicial review under Article 226 of the Constitution of India is extremely limited."
The petitioner, a first-year MBA student at NALSAR University, challenged the University's refusal to issue her a hall ticket for the Semester-II supplementary examinations. She sought permission to appear in the remaining supplementary examinations, contending that she had suffered from viral pneumonia, lower respiratory tract infection, severe dehydration and other ailments during February and March 2026, resulting in shortage of attendance. She argued that denial of permission would compel her to repeat the entire first-year MBA programme despite genuine medical circumstances.
The petitioner submitted that after recovering from her illness, her parents had represented to the University seeking condonation of attendance shortage. She claimed that the Head of the Department had initially assured her that she would be permitted to write the supplementary examinations, but she was later informed that because she had more than four backlogs arising from her detention, she would have to repeat the first year. She contended that the University's rules recognised medical leave and vested discretion in the authorities to grant relaxation in deserving cases.
The University opposed the petition, submitting that under Rule 4.6 of the MBA Rules, students require at least 75% attendance to appear in end-term examinations, while even students granted medical leave must secure a minimum attendance of 67%. It contended that the petitioner's attendance was only 52%, far below the prescribed threshold, and that Rule 5.3.5 expressly bars students detained for shortage of attendance from appearing in repeat or supplementary examinations. The University further pointed out that the petitioner had neither obtained prior permission for medical leave nor challenged her detention from the April 2026 end-term examinations at the relevant time.
The High Court noted that even according to the petitioner's own case, her attendance was only 56%, which remained below the minimum 67% attendance required even where medical leave is granted. It therefore held that she was rightly detained from the end-term examinations under Rule 4.6.
The Court observed that Rule 5.3.5 left no discretion to either the University or the Court once a student was detained from the end-term examinations for shortage of attendance, as such students were required to re-register for the course rather than appear in supplementary examinations.
The Court also noted that the petitioner had admittedly not obtained prior permission for medical leave in accordance with the prescribed procedure. Her parents' representation seeking condonation of attendance shortage and permission to write supplementary examinations was submitted only on July 6, 2026, the very day the supplementary examinations commenced. Further, although the petitioner's parents had already been informed on July 4, 2026 that she would have to repeat the first year, she did not challenge that decision until after the supplementary examinations had begun.
While acknowledging that denial of permission would result in the petitioner losing an academic year and facing financial hardship, the Court held that such considerations could not justify directing the University to act contrary to its own regulations. Finding no arbitrariness or violation of the governing rules, it dismissed the writ petition.
Case Title: S. Nandini v. NALSAR University of Law
Case No.: W.P. No. 21904 of 2026
Appearance: Dr. Lakshmi Narasimha for the petitioner; A. Kranti Kumar Reddy, Standing Counsel for NALSAR University, for the respondent.